OFAC FAQ (Current) # 1090 - Cuba Sanctions

Date issued: Sep. 26 2022

Last substantive commentary amendment:
Feb. 16 2024

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TURBOFAC Commentary (210 words)

Notes:

1) There is nothing in 515.570 or 515.572(a)(3) specifying one way or the other that qualifying "remittances" must be made through any particular medium of exchange. This FAQ clarifies that the CACR's unusually scoped remittance GLs apply to “digital payments,” which "means transfers of funds sent through mobile money, mobile wallets, digital bank accounts, credit/debit cards, online payments, or other digital technology." (Compare/contrast Earthquake Relief Efforts in Syria - Question # 6).

2) Query: is "other digital technology" cryptocurrency (which OFAC also refers to as "digital currency")? Most likely. There is nothing to suggest that the broad definition of "digital payments" excludes digital currency, and given its prominence, one would imagine that OFAC would say that it is excluded from "digital payments" if OFAC intended that result.

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